Government Resolution on the National Anti-Corruption Strategy and Action Plan 2021-2023
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Government Resolution on the National Anti-Corruption Strategy and Action Plan 2021–2023 P U B L I C AT I O N S O F T H E F I N N I S H G O V E R N M E N T 2020:68 vn.fi/en
Publications of the Finnish Government 2021:68 Government Resolution on the National Anti-Corruption Strategy and Action Plan 2021–2023 Ministry of Justice, Finland, Helsinki 2021
Ministry of Justice, Finland © 2021 Authors and Ministry of Justice ISBN pdf: 978-952-383-678-5 ISSN pdf: 2490-0966 Layout: Government Administration Department, Publications Helsinki 2021, Finland
Description sheet
7 September 2021
Government Resolution on the National Anti-Corruption Strategy and
Action Plan 2021–2023
Publications of the Finnish Government 2021:68
Publisher Finnish Government
Author(s) Juuso Oilinki
Group author Ministry of Justice and the Preparation and Steering group for the National Anti-Corruption
Strategy and Action Plan
Language English Pages 43
Abstract In November 2019, the Ministerial Working Group on Internal Security and
Strengthening the Rule of Law decided to launch further preparation of an anti-
corruption strategy. On 23 April 2020, the Ministry of Justice appointed a preparation
and steering group to draft an anti-corruption strategy and action plan.
The group utilised the draft strategy formulated by the anti-corruption cooperation
network in the preparation of the Strategy and Action Plan. The preparation work
also took into account the UN Sustainable Development Goals (2030 Agenda) and
the recommendations issued by the UN, the OECD, the Council of Europe and the
European Union to Finland to reinforce its anti-corruption work.
The objective of the Strategy is to intensify the fight against corruption in the short
term, and in the long term to build a society where corruption has no chance of
success. To reach the objectives of the Strategy, the preparation and steering group
drew up the Action Plan, which includes scheduled measures for which different
authorities and stakeholders are responsible.
The Action Plan will be implemented in 2021–2023. The preparation and steering
group will monitor the implementation and report on the progress to the Ministerial
Working Group on Internal Security and Strengthening the Rule of Law.
Keywords corruption, criminal policy, crime prevention, ethics, good governance
ISBN PDF 978-952-383-678-5 ISSN PDF 2490-0966
Project no. OM045:00/2020
URN address http://urn.fi/URN:ISBN:978-952-383-678-5Kuvailulehti
7.9.2021
Valtioneuvoston periaatepäätös kansalliseksi korruptionvastaiseksi
strategiaksi ja toimenpideohjelmaksi 2021–2023
Valtioneuvoston julkaisuja 2021:68
Julkaisija Valtioneuvosto
Tekijä/t Juuso Oilinki
Yhteisötekijä Oikeusministeriö ja Korruptionvastaisen strategian ja toimenpideohjelman valmistelu- ja
ohjausryhmä
Kieli englanti Sivumäärä 43
Tiivistelmä Oikeusvaltion kehittämisen ja sisäisen turvallisuuden ministeriryhmä päätti
marraskuussa 2019 käynnistää korruption vastaisen strategian jatkovalmistelun.
Oikeusministeriö asetti 23.4.2020 valmistelu- ja ohjausryhmän korruptionvastaisen
strategian ja sitä koskevan toimenpideohjelman valmistelua varten.
Valmistelussa hyödynnettiin korruptionvastaisen yhteistyöverkoston laatimaa
strategialuonnosta. Strategian ja toimenpideohjelman valmistelussa on myös
huomioitu YK:n, OECD:n, Euroopan neuvoston ja EU:n Suomelle osoitetut
korruption vastaisen työn tehostamiseen liittyvät suositukset sekä YK:n kestävän
kehityksen (Agenda 2030) tavoitteet.
Strategialla pyritään lyhyellä aikavälillä tehostamaan korruption torjuntaa ja pitkällä
aikavälillä rakentamaan yhteiskuntaa, jossa korruptiolla ei ole menestymisen
mahdollisuuksia. Strategian tavoitteiden saavuttamiseksi valmistelu- ja ohjausryhmä
laati toimenpideohjelman, joka sisältää aikataulutettuja ja vastuutettuja toimenpiteitä.
Toimenpideohjelman toimeenpano tapahtuu vuosina 2021–2023. Valmistelu- ja
ohjausryhmä seuraa toimeenpanoa ja raportoi siitä oikeusvaltion kehittämisen ja
sisäisenturvallisuuden ministeriryhmälle.
Asiasanat korruptio, kriminaalipolitiikka, rikoksentorjunta, etiikka, hyvä hallinto
ISBN PDF 978-952-383-678-5 ISSN PDF 2490-0966
Hankenumero OM045:00/2020
URN-adress http://urn.fi/URN:ISBN:978-952-383-678-5Presentationsblad
7.9.2021
Statsrådets principbeslut om en nationell strategi och ett
åtgärdsprogram för bekämpning av korruption 2021–2023
Statsrådets publikationer 2021:68
Utgivare Statsrådet
Författare Juuso Oilinki
Utarbetad av Justitieministeriet och Berednings- och styrgruppen för strategin och åtgärdsprogrammet för
bekämpning av korruption
Språk engelska Sidantal 43
Referat Ministerarbetsgruppen för utvecklande av rättsstaten och för inre säkerhet beslutade
i november 2019 att inleda den fortsatta beredningen av en strategi mot korruption.
Den 23 april 2020 tillsatte justitieministeriet en berednings- och styrgrupp för
beredning av strategin mot korruption och det åtgärdsprogram som gäller den.
Vid beredningen användes det strategiutkast som utarbetats av samarbetsnätverket
mot korruption. I arbetet har också beaktats FN:s, OECD:s, Europarådets och EU:s
rekommendationer till Finland om en intensifiering av antikorruptionsarbetet samt
FN:s mål för hållbar utveckling (Agenda 2030).
På kort sikt är målet med strategin att effektivisera bekämpningen av korruption och
på lång sikt att bygga upp ett samhälle där korruption inte kan få fotfäste. För att nå
målen i strategin utarbetade berednings- och styrgruppen ett åtgärdsprogram som
innehåller schemalagda åtgärder med definierade ansvariga.
Åtgärdsprogrammet genomförs 2021–2023. Berednings- och styrgruppen följer upp
genomförandet av programmet och rapporterar om utfallet till ministerarbetsgruppen för
utvecklande av rättsstaten och för inre säkerhet.
Nyckelord korruption, kriminalpolitik, brottsbekämpning, etik, god förvaltning
ISBN PDF 978-952-383-678-5 ISSN PDF 2490-0966
Projektnr. OM045:00/2020
URN address http://urn.fi/URN:ISBN:978-952-383-678-5Contents
1 Covernment Resolution on the National Anti-Corruption
Strategy and Action Plan 2021–2023 ........................................................ 7
2 Current state................................................................................................ 8
3 General ......................................................................................................... 9
4 Key development areas for combating corruption set out in
the Strategy ............................................................................................... 10
5 Action Plan of the Anti-Corruption Strategy for 2021–2023 ................. 13PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
1 Covernment Resolution on the
National Anti-Corruption Strategy
and Action Plan 2021–2023
The aim of the Anti-Corruption Strategy is to:
1. commit public administration and political actors to combat corruption
effectively;
2. promote the identification of corruption and the transparency of
decision-making;
3. seek to improve the ability of authorities to hold those who have engaged
in corrupt practices accountable for their actions;
4. facilitate the creation of national situation awareness of corruption.
7PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
2 Current state
Corruption is harmful in many ways to individuals and society at large. Corruption has
serious consequences that slow down economic development, and that undermine
democracy, the implementation of human rights and competitiveness. If no effective
efforts are made to prevent corruption, the credibility of the rule of law will also be
weakened.
Corruption means any abuse of a position of authority for personal gain. No country is
without corruption, and this holds true for Finland as well. While open ‘street-level’
corruption is very rare in Finland, studies show that corruption exists in Finland at all
levels of society and in many different sectors and contexts. Instead of street-level
corruption, structural corruption that is more difficult to detect appears in Finland. This
kind of corruption occurs often in the interface between the public and private sectors
and as part of other economic crime. Corruption in Finland is, to a large extent, hidden
crime, and only some of the corruption offences are brought to the attention of the au-
thorities. Statistical data on corruption are incomplete and relatively little research has
been carried out on corruption. High-risk sectors for corruption are construction, public
procurement and competitive tendering, urban planning, political decision-making,
and party and election funding. Other areas with a high risk of corruption are foreign
trade and sports. Corruption typically takes the form of giving and accepting undue
advantages, conflicts of interest and favouritism. It also appears in the form of unethi-
cal preparation of decisions outside the formal decision-making structures.
The importance of preventing and combating corruption is raised in several interna-
tional conventions, recommendations, guidelines and other publications. It has been
stressed in many contexts how important it is to take systematic and determined ac-
tion against corruption. For example, Article 5 of the United Nations Convention
against Corruption (UNCAC) requires that the States Parties to the Convention shall
develop and implement or maintain effective, coordinated anti-corruption practices
and policies. Reducing corruption and bribery is one of the targets under the UN Sus-
tainable Development Goals, which were adopted in September 2015 by Finland
among other countries. This means that Finland is expected to adopt measures to re-
duce corruption in all its forms by 2030. In addition, Finland is committed to the work
of the Organisation for Economic Co-operation and Development (OECD), the Council
of Europe and the European Union against corruption as part of international anti-cor-
ruption cooperation.
8PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
3 General
In November 2019, the Ministerial Working Group on Internal Security and Strength-
ening the Rule of Law decided to launch further preparation of an anti-corruption strat-
egy. The short-term objective of this Strategy is to reinforce the prevention and com-
bating of corruption. The vision and long-term objective of the Strategy is to build a
society where corruption cannot take hold or go unnoticed.
The Strategy will have a preventive effect on corruption and will strengthen ethically
sound practices in public administration and companies. The Strategy and the related
Action Plan will also help to prevent and combat corruption in the context of public
procurement and increase the transparency of procurement, which in turn will pro-
mote healthy competition. Additionally, the Strategy will have a positive impact on the
transparency and credibility of political decision-making.
As outlined in the Government Programme, the Anti-Corruption Strategy will support
the implementation of sustainable development objectives, such as those aimed at
the strengthening of the rule of law and good governance, and the reduction of cor-
ruption and bribery. Measures under the Action Plan of the Strategy may be imple-
mented as separate projects or as part of other strategies of the Government, such as
the Action Plan for Tackling the Grey Economy and Economic Crime.
The Strategy is in line with the UN Sustainable Development Goals (2030 Agenda)
and the recommendations issued by the UN, the OECD, the Council of Europe and
the European Union to Finland to reinforce its anti-corruption work.
9PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
4 Key development areas for
combating corruption set out in
the Strategy
Although anti-corruption work has been intensified in recent years, the Government
considers that the work to combat corruption should be more systematic and compre-
hensive at national level. On 23 April 2020, the Ministry of Justice appointed a prepa-
ration and steering group to draft an anti-corruption strategy and action plan for Fin-
land to improve the effectiveness of anti-corruption and prevention measures. In
2015, the anti-corruption cooperation network started preparing a draft anti-corruption
strategy. In preparing the Strategy and Action Plan, the preparation and steering
group utilised the draft strategy formulated by the anti-corruption cooperation network
(2017).
Finland's active participation in international anti-corruption work, including the fight
against cross-border crime and the fulfilment of international treaty obligations at na-
tional level and as part of Finland's external relations, are incorporated across the
board in the development areas listed below.
Key development areas for the combating of corruption are:
1. Reinforcement and clarification of the official structures for pre-
venting and combating corruption and improvement of cooperation
between the parties involved
The structures of anti-corruption work in Finland will be reinforced and
clarified and clear responsibilities will be established. In cross-adminis-
trative cooperation, means will be developed to improve the effective-
ness of anti-corruption work and to implement the Strategy.
2. Raising awareness of corruption
To raise awareness of corruption, training will be organised for different
target groups, and the Ministry of Justice's website, korruptiontorjunta.fi,
and various other sources of information will be actively updated and
utilised. It will be ensured that the authorities have both sufficient
awareness of corruption and the necessary skills to combat corruption.
Material relating to the prevention and combating of corruption will be
10PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
drawn up for different target groups, such as public officials (state and
municipalities), companies and the sectors at risk of corruption.
3. Increase in transparency
In line with the Government Programme, transparency will be promoted
in all decision-making. In particular, the transparency of the acts of pub-
lic authorities and political activities will be promoted. Measures will be
explored and implemented to enhance the identification and monitoring
of private interests and conflicts of interest, including through the wider
use of the transparency register and open data. At the same time,
measures will be sought and taken to increase transparency in the eco-
nomic activities and decision-making principles of publicly owned com-
panies, for example through improving access to documents and open-
ness of decision-making.
4. Promoting the exposure of corruption
To intensify the exposure of corruption requires better operating condi-
tions for key authorities. The exposure of corruption cases will be en-
hanced by improving access to information for authorities central to the
fight against corruption and by promoting opportunities for reporting.
For example, the EU Directive on the protection of whistleblowers re-
quires wide-ranging awareness raising and possibly reorganisation of
official structures for the establishment of a confidential reporting chan-
nel. Increasing awareness of corruption is essentially linked to enhanc-
ing the exposure of cases.
5. Examination of the functioning of legislation relevant to the preven-
tion of corruption, and the development of legislation
To assess the functioning of legislation relevant to preventing corrup-
tion and to develop such legislation, it will be examined how the crimi-
nal procedure works in connection with bribery offences, for example.
The aim is to examine potential problems in the identification of bribery
cases and in criminal procedures, and to evaluate and implement other
key measures in the fight against corruption.
6. Promotion of research related to corruption and its prevention
To increase up-to-date information, research on corruption will be pro-
moted. Only a small amount of information is available on the corrup-
tion occurring in Finland. Corrupt practices tend to take place away
11PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
from the public eye, and annually only a few suspected cases of corrup-
tion are reported to the police or other authorities. Very few corruption
cases come to the attention of the authorities or the public.
To reach these objectives, the Action Plan of the Strategy includes scheduled
measures, and the implementation and effectiveness of these will be monitored and
assessed. The Strategy and Action Plan were drawn up by the preparation and steer-
ing group led by the Ministry of Justice and presented to the Ministerial Working
Group on Internal Security and Strengthening the Rule of Law. The task of the prepa-
ration and steering group appointed by the Ministry of Justice is to guide and coordi-
nate the implementation of the Strategy and the related Action Plan and to report on
the progress of the measures to the Ministerial Working Group on Internal Security
and Strengthening the Rule of Law.
12PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
5 Action Plan of the Anti-Corruption Strategy for 2021–2023
Each authority implements their planned measures within their own jurisdiction in accordance with relevant statutes.
1. Reinforcement and clarification of the official structures for preventing and combating corruption and improvement of cooperation between the
parties involved
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
1.1.1. Coordination and Set up an operational cooperation National Prosecution 2021 Carried out as Working group appointed.
cooperation to be en- group to enhance the fight against Authority, National Bu- part of official du- (Yes/No)
hanced. corruption and to improve opera- reau of Investigation / ties. Reporting of results.
tional cooperation between the au- Helsinki Police Depart-
thorities. ment, Finnish Compe-
tition and Consumer
Authority, Finnish Tax
Administration, Finan-
cial Intelligence Unit,
Customs
Ministries appoint contact persons Ministries 2021 Carried out as Contact persons appointed by ministries
for the prevention and combating of part of official (number).
corruption to draw attention to cor- duties. Operations launched.
ruption issues within their own organ- (Yes/No)
13PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
isation, to monitor the implementa-
tion of the Anti-Corruption Strategy
and report on it to the Ministry of Jus-
tice, which supports ministries in
anti-corruption work.
1.1.2. Exposure of cor- With existing structures and re- Ministry of the Interior, 2021 Carried out as National Bureau of Investigation’s anti-
ruption offences and sources strengthen the National Bu- National Police Board, part of official corruption function strengthened.
support for investigation. reau of Investigation’s anti-corruption National Bureau of In- duties. (Yes/No)
function, utilising existing official vestigation Reporting of results.
structures and focusing on the detec-
tion of corruption offences and sup-
port for investigation.
The function is responsible for
– collecting operative tips, intelli-
gence and information and other re-
ports on corruption, for their analysis
and for bringing cases for criminal in-
vestigation on a national level,
– disseminating good practices and
for communications to make preven-
tion successful,
14PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
– maintaining the operational situa-
tion awareness of the police con-
cerning corruption,
– receiving and analysing investiga-
tion requests, tips and other infor-
mation from authorities, and bringing
cases for criminal investigation on a
national level,
– coordinating the national contact
person network of the police,
– developing national and interna-
tional cooperation between authori-
ties and stakeholders, and improving
the exchange of information jointly
with the National Police Board and
other police departments.
1.1.3. Development of The police, the Border Guard and National Police Board, 2022 Carried out as Strategy/policy prepared.
anti-corruption activities Customs develop anti-corruption Border Guard, Cus- part of official (Yes/No)
by criminal investigation strategies and policies that are com- toms duties.
authorities. municated to the general public
(GRECO 5, paragraph 129).
15PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
(i) Prepare rules/requirements for ap- National Police Board, 2022 Carried out as Rules of procedure prepared and
propriate procedures for the police, Border Guard, Cus- part of official published.
the Border Guard and Customs from toms duties. (Yes/No)
the perspective of integrity and anti-
corruption, which are made easily
accessible to the public; (ii) supple-
ment these rules/requirements with
practical implementation measures,
including, in particular, confidential
advisory services and special, man-
datory induction and continuing train-
ing.Pay particular attention to ethical
management training (GRECO 5,
paragraph 132).
Ensure that the recruitment and ca- National Police Board, 2022 Carried out as Reporting on the implementation of the
reer advancement processes of the Border Guard and part of official measures.
police, the Border Guard and Cus- Customs duties. (Yes/No)
toms (i) use appropriate inspections
and supervision to prevent an indi-
vidual from having an inappropriate
influence on the process and (ii)
build internal complaint/mediation
mechanisms (GRECO 5, paragraph
140).
16PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
Develop a functioning system for out- National Police Board 2022 Carried out as System developed.
side employment permits for the po- part of official (Yes/No)
lice and organise effective monitor- duties.
ing of this system (GRECO 5, para-
graph 151).
Develop guidance for the police, Bor- National Police Board, 2022 Carried out as Guidance arranged.
der Guard and Customs on the re- Border Guard and part of official (Yes/No)
quirements and procedures that offi- Customs duties.
cials must follow when forming pri-
vate interests and taking up outside
employment and when negotiating
on a future employment contract,
which they will enter into after work-
ing for the police, the Border Guard
or Customs (GRECO 5, paragraph
152).
(i) Prepare a plan on the collection of National Police Board 2022 Carried out as Plan prepared and internal oversight
data to further improve police risk part of official enhanced.
management to prevent corruption; duties. (Yes/No)
and (ii) allow more stringent internal
oversight through regular cross-
checks and inspection of registers
(GRECO 5, paragraph 163);
17PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
(i) Require the police, border authori- National Police Board, 2022 Carried out as Provisions laid down on the reporting
ties and customs authorities to report Border Guard and part of official obligation, and the protection of whistle-
corruption and (ii) enhance, in this Customs duties. blowers improved.
respect, the protection of whistle- (Yes/No)
blowers (GRECO 5, paragraph 168);
Organise special guidance and train- National Police Board, 2022 Carried out as Guidance and training organized.
ing on the protection of whistleblow- Border Guard and part of official (Yes/No)
ers at all hierarchy levels in the po- Customs duties.
lice, the Border Guard and Customs
(GRECO 5, paragraph 169).
1.1.4. Measures aimed Take steps to ensure that after the National Prosecution 2021–2023 Carried out as Reporting.
at ensuring that authori- planned restructuring of the prosecu- Authority part of official
ties acting in the criminal tion service, cases concerning for- duties.
procedure chain have eign corruption will be referred to
adequate means to com- prosecutors with sufficient expertise
bat corruption will be en- and experience on the subject
hanced. (OECD 4, 2a).
Take steps to ensure that the re- National Police Board, 2021–2023 Carried out as Reporting.
sources allocated to the National Bu- National Bureau of In- part of official
reau of Investigation to combat for- vestigation, National duties.
eign bribery are kept at the current Prosecution Authority
level and that the prosecution ser-
18PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
vice's resources are sufficient to ena-
ble prosecutors to continue to partici-
pate in the investigation of foreign
bribery cases at an early stage
(OECD 4, 2b).
Take steps to ensure that courts and National Courts Admi- 2021–2023 Carried out as Reporting.
judges dealing with foreign corrup- nistration part of official (Yes/No)
tion cases have specialised expertise duties.
and experience in dealing with such
cases (OECD 4, 2c).
Prepare detailed, written material for Ministry of Justice, Na- 2022 Carried out as Prepared.
criminal investigators, prosecutors tional Courts Admin- part of official (Yes/No)
and judges (either jointly or sepa- istration, National duties utilising the
rately) on what is required to fulfil the Prosecution Authority, results of the
essential elements of a foreign brib- National Police Board Government’s
ery offence in accordance with Arti- analysis, assess-
cle 1 of the Convention (e.g. OECD ment and re-
4, 3a). search activities
(TEAS) project
concerning evi-
dence require-
ment analysis.
19PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
Plan comprehensive training, using Ministry of Justice, Na- 2021–2023 Carried out as Training organized.
the information specified above in tional Police Board, part of official (Yes/No)
Recommendation 3a, for criminal in- National Prosecution duties.
vestigators, prosecutors and judges Authority, National
on the application of the definition of Courts Administration
foreign bribery offences (OECD 4,
3b).
Encourage prosecutors to make full National Prosecution 2021–2023 Carried out as Reporting.
use of the possibility of demanding Authority part of official
business prohibitions in foreign cor- duties.
ruption cases (OECD 4, 4a).
20PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
2. Raising awareness of corruption
2.1. General awareness of corruption
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
2.1.1. People know what Maintain and update the national Ministry of Justice and 2021–2023 Carried out as The site is being updated and is in active
corruption means and anti-corruption website (www.korrup- the anti-corruption co- part of official use.
understand the damage tiontorjunto.fi) through which the pub- operation network and duties. (Yes/No)
it causes. lic, companies and authorities re- contact persons from Visitor numbers 2020, 2021, 2022, 2023
ceive objective, fact-based infor- ministries
mation on corruption and reporting
practices.
Actively communicate anti-corruption Ministry of Justice and 2021–2023 Carried out as Active distribution of information.
actions on the websites and in the the anti-corruption co- part of official (Yes/No)
newsletters of authorities/agencies operation network duties.
and in the media. Agency contact per-
sons in matters related
to corruption
Organise training and distribute anti- (Ministry of Education 2021–2023 Carried out as Training organized.
corruption and prevention materials and Culture) part of official (Yes/No)
to the branch of government of the duties.
Ministry of Education and Culture.
21PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
Highlight the importance of the fight Ministry of Justice, Annually/on Carried out as Annual events.
against corruption at various public the anti-corruption co- 9 December part of official (Yes/No)
events and special events aimed at operation network and duties.
increasing corruption awareness in stakeholders
conjunction with the Anti-Corruption
Day.
2.1.2. An effort will be Develop interaction between authori- Ministry of Justice and 2021–2023 Carried out as New forms of cooperation developed.
made to increase the ties and the media through new the anti-corruption co- part of official (Yes/No)
awareness of media rep- forms of cooperation. operation network duties.
resentatives in the area
of corruption and its pre-
vention.
2.1.3. Increase the Take steps to raise awareness of ex- Ministry of Justice, 2021–2023 Carried out as Awareness increased.
awareness of corruption isting guidelines (e.g. OECD guide- Ministry of Economic part of official (Yes/No)
that takes place abroad. lines) and of how corruption abroad Affairs and Employ- duties.
in the private sector can be tackled, ment, Ministry of Fi-
including in sectors where risks are nance, Ministry of De-
high, such as the defence industry, fence, and stakehold-
state-owned companies, SMEs, and ers
in sectors for legal advice, and ac-
counting and auditing professionals
(OECD Recommendation 3, 5c).
22PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
2.1.4. National situation Design a monitoring method, and Ministry of Justice, 2022–2023 Requires addi- Monitoring method prepared and report
awareness of corruption prepare a situation report on corrup- Police University Col- tional funding, for published.
will be developed and tion every two years. lege which an applica- (Yes/No)
maintained. tion has been
submitted to the
Internal Security
Fund (ISF).
2.2. Awareness of corruption and the development of expertise in combating corruption in the public sector
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
2.2.1. Awareness among Prepare and implement ethics guide- Ministry of Finance 2021–2023 Funding in part Guidelines prepared and shared with
state, municipal and re- lines on preventing and combating and Ministry of Justice under project 1.3 relevant parties.
gional government offi- corruption for state and municipal of- in cooperation with of the Action Plan (Yes/No)
cials, employees and ficials and for other local and re- other ministries for Tackling the
elected officials of the gional operators, including publicly Grey Economy
forms of manifestation of owned companies. and Economic
corruption and its harm- Crime.
ful effects, and of the Otherwise carried
means to combat corrup- out as part of offi-
tion will be increased. cial duties.
23PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
Launch a separate corruption and Ministry of Justice, 2021–2023 Carried out as Website created.
ethics website aimed specifically at Ministry of Finance part of official (Yes/No)
officials under the national anti-cor- and Prime Minister's duties. Online training created and introduced.
ruption website (korruptiontorjunta.fi) Office (Yes/No)
that will include an online training
module on corruption. Shared using eOppiva.
An effort will be made to use this (Yes/No)
training as part of the induction of The training is now part of the induction
new officials. of new officials.
(Yes/No)
Organise thematic training on the Ministry of Justice and 2021–2023 Funding in part Training organized.
risks of corruption for officials, inter- other ministries under project 1.3. (Yes/No)
nal auditors and elected officials en- Will be implemented of the Action Plan Survey sent to participants on the useful-
gaging in recruitment, zoning and as part of the Action for Tackling the ness of the training.
land use planning, procurement, con- Plan for Tackling the Grey Economy (Yes/No)
struction contracts and government Grey Economy and and Economic
grants. Economic Crime in co- Crime.
operation with stake- Otherwise carried
holders. out as part of offi-
cial duties.
2.2.2. Officials and Give specialised, and when neces- Police University Col- 2021–2023 Carried out as Training completed.
elected officials partici- sary, joint training sessions, on cor- lege, National Prose- part of official (Yes/No)
pating in anti-corruption ruption to special prosecutors, police cution Authority, Minis- duties
work have the necessary try of Justice, Finnish
24PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of implementation
meet targets responsibility (implemented)
Other bodies
knowledge and skills re- officers, the staff at courts of law and Competition and Con- Number of persons trained?
quired for the prevention the Financial Intelligence Unit. sumer Authority, Na- Feedback?
of corruption, the fight tional Bureau of Inves-
against corruption and tigation, National
the investigation of cor- Courts Administration
ruption.
Organise training for the police and National Prosecution 2021–2023 Carried out as Training completed.
prosecution service organisations on Authority, National Po- part of official (Yes/No)
the recovery of proceeds from cor- lice Board, National duties. Number of persons trained?
ruption-related offences (OECD 4, Bureau of Investiga-
5b). tion, Police University Feedback?
College
2.3 Awareness of corruption in political activities
Target Measures taken to Principal Schedule Resource Assessment of
meet targets responsibility (implemented) implementation
Other bodies
2.3.1. Increase the aware- Provide material on corruption and its Parliament, Ministry of 2022–2023 Carried out as part of Materials prepared
ness of corruption among manifestation to political parties, new Justice official duties. and distributed.
political actors. MPs and other political representatives. (Yes/No)
25PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of
meet targets responsibility (implemented) implementation
Other bodies
2.3.2. Increase the aware- Investigate the necessary measures Prime Minister's Of- 2021–2022 Carried out as part of Investigated and
ness of corruption among (e.g. rules of procedure, training, guid- fice: ministers official duties. implemented.
ministers and senior offi- ance and advisory services, monitoring Ministry of Finance: (Yes/No)
cials in central govern- and sanction mechanisms) for increas- senior officials
ment. ing the awareness of senior officials in
central government on corruption Ministry of Finance
(GRECO, paragraph 46, 48 and 65). and Prime Minister's
Office: political state
secretaries and spe-
cial advisers
(working group)
Lay down provisions on procedures for Prime Minister’s Office 2021–2022 Carried out as part of Provisions in force.
preventing and avoiding conflicts of in- official duties. (Yes/No)
terest situations when members of Gov-
ernment move to other positions.
26PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
2.4. Awareness of corruption in the private sector
Target Measures taken to Principal Schedule Resource Assessment of
meet targets responsibility (implemented) implementation
Other bodies
2.4.1. Steps will be taken State-owned companies will draw up an Prime Minister's Office 2022 Carried out as part of State-owned compa-
to increase the awareness action plan against corruption and imple- (Ownership Steering official duties. nies have anti-corrup-
of employees of state- ment it in accordance with OECD guide- Department) tion action plans in
owned companies on cor- lines. place (%).
ruption and the fight Action plans imple-
against corruption. mented.
(Yes/No)
2.4.2. Steps will be taken Organise discussion events on responsi- Ministry of Economic 2021–2023 Funding in part under Seminars organized.
to increase the awareness ble business for companies engaged in Affairs and Employ- project 1.3 of the Ac- (Yes/No)
of companies engaged in international trade; these will include a ment, Ministry for For- tion Plan for Tackling Survey sent to training
international trade on cor- section on corruption in international eign Affairs, Ministry of the Grey Economy session participants on
ruption and the fight business relationships, its conse- Justice (in cooperation and Economic Crime. the usefulness of the
against corruption. quences and means for its prevention. with Business Finland Otherwise carried out seminar: in better un-
Prepare and collect guideline materials and key business or- as part of official du- derstanding of corrup-
on the topic. Where possible, utilise ex- ganisations, compa- ties and in coopera- tion phenomena.
isting structures, channels and mecha- nies and other relevant tion with other key (Yes/No)
nisms. parties) parties.
2.4.3. Awareness of SMEs Continue the marketing of the anti-cor- Ministry of Justice, 2021–2023 Funding in part under Awareness increased.
concerning corruption and ruption guide prepared by the Ministry of Ministry of Economic project 1.3 of the Ac- (Yes/No)
anti-corruption will be in- Economic Affairs and Employment for tion Plan for Tackling
creased. SMEs with stakeholders and participate
27PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of
meet targets responsibility (implemented) implementation
Other bodies
in the planning and implementation of Affairs and Employ- the Grey Economy
training and seminars for SMEs. ment, and stakehold- and Economic Crime.
ers Otherwise carried out
as part of official du-
ties and in coopera-
tion with other key
parties.
2.4.4. Companies and Organise training on responsible busi- Ministry for Foreign Annually Carried out as part of Training organized.
other private actors receiv- ness practices, good administration, and Affairs/ official duties. (Yes/No)
ing development coopera- statutes, conditions, restrictions and Finnpartnership, com- Survey sent to partici-
tion funding know what principles related to the use of discre- panies pants on the useful-
corruption means and un- tionary government grants, including a ness of the training.
derstand the damage it section on the harmful effects, sanctions (Yes/No)
causes. and prevention measures of corruption,
for companies receiving development
cooperation funding (Ministry for Foreign
Affairs/Finnfund, etc.) and other private
actors. Where possible, utilise existing
structures, channels and mechanisms.
2.4.5. Employees at enter- Offer seminars to enterprises in the con- Ministry of Justice, 2021–2023 Funding in part under Seminars organized.
prises in the construction struction sector that focus on corruption Ministry of the Envi- project 1.3 of the Ac- (Yes/No)
sector know what corrup- and cartels in the construction sector, ronment, Finnish Com- tion Plan for Tackling Survey sent to semi-
tion means and understand petition and Consumer the Grey Economy nar participants on the
the damage it causes. Authority, the police, and Economic Crime.
28PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of
meet targets responsibility (implemented) implementation
Other bodies
the damage caused by corruption, sanc- the Finnish Tax Ad- Otherwise carried out usefulness of the sem-
tions for corruption and means of pre- ministration and stake- as part of official du- inar.
venting corruption. holders ties and in coopera- (Yes/No)
tion with other key
parties.
2.4.6. Parties subject to the Offer training to parties subject to the re- National Bureau of In- 2021–2023 Carried out as part of Training organised.
reporting obligation under porting obligation under the Anti-Money vestigation, Regional official duties. (Yes/No)
the Anti-Money Laundering Laundering Act and other reporting bod- State Administrative
Act know what corruption ies on the more effective identification of Agencies, Ministry of
means and recognise its corruption. Justice, Police Univer-
various forms. sity College
2.4.7. Efforts will be made Take steps to increase awareness of the Ministries 2021–2023 Carried out as part of Awareness increased.
to raise awareness of cor- fight against corruption so that parties official duties. (Yes/No)
ruption among parties re- receiving government grants are familiar
ceiving significant govern- with the principles of good administra-
ment grants. tion and the necessary processes and
legislation related to the use of govern-
ment grants.
2.4.8. Consideration of dis- Add good administration that includes (Ministry of Education 2021 Carried out as part of Criteria taken into
cretionary government measures against the manipulation of and Culture) official duties. account in considera-
grants to organisations sports competitions (match fixing) to the tion of discretionary
promoting physical activity government grants.
will include an assessment (Yes/No)
of how the organisations
29PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of
meet targets responsibility (implemented) implementation
Other bodies
implement the principles of criteria for granting discretionary govern-
good administration in their ment grants to organisations promoting
activities. physical activity.
3. Increasing transparency
3.1. Increasing transparency in official activities
Target Measures taken to Principal Schedule Resource Assessment of
meet targets responsibility (implemented) implementation
Other bodies
3.1.1. Transparency of de- Take steps to investigate and assess Ministry of Justice 2021–2023 Carried out as part of Investigated.
cision-making will be in- the appropriate implementation of the official duties. (Yes/No)
creased in accordance with principle of openness, the problem ar- Targets achieved.
the Government Pro- eas in its implementation and measures (Yes/No)
gramme. that will impact these.
3.1.2. Steps will be taken Assess the grounds for the appointment Ministry of Finance 2021 Carried out as part of Investigation
to examine ways to make of senior officials and examine the official duties. completed.
appointment processes of length of the periods in office as part of (Yes/No)
senior officials more trans- the power to appoint and, if necessary,
parent. update the relevant guidelines. Addition-
ally, investigate the functioning of the
30PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal Schedule Resource Assessment of
meet targets responsibility (implemented) implementation
Other bodies
prohibition of appeal laid down in the Act
on Public Officials in Central Govern-
ment.
3.1.3. Steps will be taken Officials dealing with exceptionally sen- Ministry of Finance 2022–2023 Carried out as part of Non-compete agree-
to limit or prevent the use sitive information or information with sig- official duties. ments are being pre-
of confidential information, nificant economic value are required to pared with information
or other information pro- sign a non-compete agreement, making on the length of a po-
tected by provisions limit- it possible to impose a non-compete pe- tential non-compete
ing its disclosure, and of riod before they can take up employ- period.
the related knowledge in ment with another employer (see (Yes/No)
an employment relation- GRECO 5, paragraph 82). Investigation com-
ship or activity for personal Investigate possibilities to extend the pleted.
gain or the gain of another, same practice to regional and municipal (Yes/No)
or to the detriment of an- officials.
other in situations where
public officials leave cen-
tral government for other
work opportunities.
31PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
3.2. Increasing transparency in political activities
Target Measures taken to Principal responsibility Schedule Resource Assessment of
meet targets Other bodies (implemented) implementation
3.2.1. Transparency of Prepare and adopt a transparency Parliament prepares the legisla- 2020–2023 A Parliament-guided Government proposal
decision-making will register (lobbying register). tive proposal, and the Ministry of project set up by the submitted.
be improved. Justice in cooperation with the Government, which (Yes/No)
register authority carry out its will be carried out in
implementation. close cooperation with
stakeholders.
In connection with the preparation of Parliament prepares the legisla- 2021–2023 A Parliament-guided Guidelines prepared.
the transparency register, take steps tive proposal, and the Ministry of project set up by the (Yes/No)
to ensure that the good lobbying Justice in cooperation with the Government, which
practices to be prepared will contain register authority carries out its will be carried out in
guidelines for increasing transpar- implementation. close cooperation with
ency and combating conflicts of in- stakeholders.
terest.
3.2.2. Steps will be With regard to all senior manage- Prime Minister's Office: 2021–2022 Carried out as part of Implemented.
taken to increase the ment (including special advisers), ministers official duties. (Yes/No)
transparency of the (i) standardise and specify the con- Ministry of Finance: senior offi-
private interests of tent and timing of the requirements cials
senior officials, minis- for declarations of private interests;
ters and special advis- and (ii) consider the possibility of ex- Ministry of Finance, Prime Minis-
ers. tending the scope of the declarations ter's Office: special advisers
to include information on gifts, finan-
cial interests, secondary employment
32PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal responsibility Schedule Resource Assessment of
meet targets Other bodies (implemented) implementation
and debts of a spouse and depend-
ent family members above a certain
threshold (in which case, this infor-
mation of close relatives may not
necessarily need to be disclosed)
(GRECO 5, paragraph 95); in addi-
tion, consider whether information on
declared interests should be added
to the transparency register.
Introduce a government gift register Prime Minister’s Office 2021 Carried out as part of Introduced.
to which information on gifts received official duties. (Yes/No)
by ministers will be added.
3.3. Increased transparency in public procurement
Target Measures taken to Principal responsibility Schedule Resource Assessment of
meet targets Other bodies (implemented) implementation
3.3.1. The procure- Examine means for promoting ac- Ministry of Economic Affairs and 2021–2023 Carried out as part of Examination com-
ment process will be cess to information on direct pro- Employment, Finnish Competi- official duties. pleted and develop-
made more transpar- curements. tion and Consumer Authority ment proposals pre-
ent and healthy com- pared and, where pos-
petition will be en- sible, implemented.
hanced. (Yes/No)
33PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal responsibility Schedule Resource Assessment of
meet targets Other bodies (implemented) implementation
Investigate ways of effectively pre- Ministry of Finance, Ministry of 2021–2022 Carried out as part of Investigated.
venting conflicts of interest and pri- Economic Affairs and Employ- official duties. (Yes/No)
vate interests in decision-making in ment
contracting entities that are limited li-
ability companies.
Investigate means to improve access Ministry of Finance, Ministry of 2021 Funding in part under Means investigated
to information for contracting entities Justice, Ministry of Economic Af- project 3.1 of the Ac- and access to infor-
in connection with procurements. fairs and Employment tion Plan for Tackling mation improved.
the Grey Economy (Yes/No)
and Economic Crime.
Otherwise carried out
as part of official du-
ties.
Investigate the possibility of requiring Ministry of Finance 2020–2022 Carried out as part of Investigation
declarations of private interests from official duties. completed.
persons involved in the preparation (Yes/No)
of procurements or other means of
preventing conflicts of interest.
34PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
3.4. Promoting transparency in business
Target Measures taken to Principal responsibility Schedule Resource Assessment of
meet targets Other bodies (implemented) implementation
3.4.1. Operators have Investigate the possibility of setting Ministry of Finance/Tax Admin- 2021–2022 Resourcing will be Investigation
as much information up a public service from which the istration from the funds allo- completed.
as possible on the general public, companies and au- Will be implemented as part of cated to the Action (Yes/No)
management of corpo- thorities can easily and cost-effec- the Action Plan for Tackling the Plan for Tackling the Provisions laid down
rate responsibilities. tively verify that companies are ful- Grey Economy and Economic Grey Economy and to make the certifi-
filling their statutory obligations as Crime. Economic Crime. cates for fulfilling obli-
employers and contracting parties. gations available to
Running this type of public service the public.
would require that information on (Yes/No)
companies included in the certificate
for the fulfilment of obligations be
made public by law.
3.4.2. Transparency of In accordance with the Government Ministry of Justice 2021–2023 Carried out as part of Assessment and
publicly owned compa- Programme, take steps to assess official duties. possible changes
nies will be increased. whether the scope of the Act on the implemented.
Openness of Government Activities (Yes/No)
should be extended to include legal
persons owned or controlled by the
public sector. In the assessment,
take into account the market impacts
of the different options and the ef-
fects on the competitive position of
companies.
35PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
4. Promoting the exposure of cases of corruption
4 .1. Promoting the exposure of corruption cases in election and party funding
Target Measures taken to Principal responsibility Schedule Resource Assessment of
meet targets Other bodies (implemented) implementation
4.1.1. The prerequi- Methods will be sought to further increase Parliament will investigate. 2020–2022 A Parliament-guided Investigated.
sites for detecting the the transparency of the election funding re- project set up by the (Yes/No)
links between election ceived by local political organisations. Government.
and party funding and
corruption will be im-
proved.
Investigate the need for a legislative Parliament will investigate. 2020–2022 A Parliament-guided Investigated.
amendment that would increase the right of project set up by the (Yes/No)
the National Audit Office to obtain from third Government.
parties necessary comparative information
for the performance of control or audit tasks
free of charge, where necessary.
Take steps to determine whether it would Parliament will investigate. 2020–2022 A Parliament-guided Investigated.
be possible to draft a legislative amendment project set up by the (Yes/No)
according to which all candidates in non- Government.
municipal elections should open a separate
bank account as a campaign account and
that donations addressed to the candidate
for election should be paid to that election
account.
36PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
4.2. Promoting the exposure of corruption cases in public activities
Target Measures taken to Principal responsibility Schedule Resource Assessment of
meet targets Other bodies (implemented) implementation
4.2.1. Corrupt prac- Improve the competence of persons Ministry of Economic Affairs and 2021–2023 Carried out as part of Competence
tices in public procure- working with public procurement in Employment, Ministry of Finance official duties. improved.
ment processes will be procurement processes and procure- (Yes/No)
detected more effec- ment legislation by increasing train-
tively. ing as part of the activities of the
Public Procurement Advisory Unit
and the implementation of the objec-
tives related to increasing the com-
petence of the Hankinta-Suomi pro-
ject.
Organise training for internal auditing Principal responsibility: Ministry 2021–2023 Resourcing will be Training organised.
in municipalities to support increased of Justice from the funds allo- (Yes/No)
awareness. Others: Finnish Competition and cated to the Action
Consumer Authority, Tax Admin- Plan for Tackling the
istration, Association of Finnish Grey Economy and
Local and Regional Authorities, Economic Crime.
National Bureau of Investigation
4.2.2. The prerequi- Draw up and implement guidelines Ministry of Finance 2022 Carried out as part of Guidelines prepared
sites of internal audits on corruption risks for internal audits official duties, will pos- and implemented.
to detect corruption of central government to strengthen sibly require separate (Yes/No)
will be improved. the identification of corruption risks. financing.
37PUBLICATIONS OF THE FINNISH GOVERNMENT 2021:68
Target Measures taken to Principal responsibility Schedule Resource Assessment of
meet targets Other bodies (implemented) implementation
Examine and implement methods for Ministry of Finance 2022 Carried out as part of Examined and
strengthening the autonomy of public official duties. implemented.
sector internal audits. (Yes/No)
Examine and implement methods to Ministry of Finance 2022 Carried out as part of Examined and
ensure the adequate access of pub- official duties. implemented.
lic actors to information for the inter- (Yes/No)
nal auditing.
4.3. Facilitating easier means for reporting on suspected corruption and for the protection of the persons submitting a report
Target Measures taken to Principal responsibility Schedule Resource Assessment of
meet targets Other bodies (implemented) implementation
4.3.1. Information will Prepare guidelines on reporting Ministry of Justice 2022–2023 Funding has been ap- Guidelines prepared
be produced on the channels, reporting practices and plied for from the Inter- and published.
implementation of the protecting whistleblowers. nal Security Fund; (Yes/No)
EU Directive on the Otherwise carried out
protection of whistle- as part of official du-
blowers. ties.
Organise general communication, Ministry of Justice, external 2022–2023 Carried out as part of Training organised.
advice and guidance on reporting reporting channel official duties. (Yes/No)
and the protection of whistleblowers,
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